Tell government: All genetically engineered seeds must be labelled!
The UK government’s consultation on whether or not it will label the seeds of new GMOs will close on the 14th April. The stakes are high – they include the future viability of organic and non-GMO food production and the ability of growers and food producers in Wales, Scotland and Northern Ireland to abide by their national laws.
The questions are focussed on business impacts but the outcome will affect everyone who buys seeds. Whether you’re a commercial food producer or home gardener, now is a crucial time to fight for your freedom of choice over what you plant.
Our future in your hands?
Photo credit: Bayer Global |
Photo Credit: Sandie Clarke @honeypoppet |
The consultation is wordy and contains a lot of detail about the process of registering plant varieties. Around half of it is a questionnaire to assess the business impacts of a decision it has already made – the creation of a separate variety list for new GMOs.[i] However, one crucial policy decision is still hanging in the balance, and that is whether the seeds of new GMOs are labelled.
GM Freeze’s Executive Director Leonie Nimmo said:
“Seeds are the source of life on Earth and encapsulate our heritage of the natural world and our ancestors’ interactions with it. We need to take a firm stand to ensure that we maintain our seed freedom – a bedrock of Food Sovereignty – and to raise a unified voice against unlabelled GMO seeds.”
Consultation – links, complaint and further reading
- Respond to the consultation here to call for mandatory labelling of new GM seeds. You can do it in just ten minutes!
- Here is a link to the pdf document, for those who want to view all the questions in advance.
- See our guidance below for issues you may want to raise in your response.
- Following feedback from our members and supporters that the consultation is directed at businesses not the public, we have raised a complaint with DEFRA. See also the Press Release.
- For more information on the deregulation of new GMOs, see This Changes Everything: New GMOs coming soon.
Background info
Precision breeding is not breeding
The consultation relates to certain newer forms of genetically engineered organisms that the UK government classifies as “Precision Bred”. These are defined as plants and animals that have had their genomes altered by modern forms of biotechnology, but with resulting changes that “could have” happened from traditional processes. It’s a “staggeringly imprecise”[ii] definition which is scientifically contested. The process does not involve breeding.
In the ‘Questions’ section below we use the term Precision Bred Organisms (PBO) because it is used throughout the consultation. However, we note that it is not a scientifically meaningful definition but rather a political construct to enable the deregulation of a sub-category of genetically engineered organisms. Elsewhere we use the term ‘new GMOs’.
The GenTech Act
The Genetic Technology (Precision Breeding) Act was passed in 2023 and earlier this year the government laid secondary legislation that will operationalise the Act. This is expected to be waved through by Parliament in the coming months. It will mean that unlabelled and untraceable new GMOs will be entering our farming and food systems. They will not have been assessed for their safety or environmental impacts, and are likely to lead to a proliferation of patents that will affect traditional plant breeders.
Seed freedom of choice
With these laws the government has been systematically dismantling our key protections against new GMOs. This consultation highlights the latest threat: our right to know whether the seeds we buy and plant have been genetically engineered. Without labels on seed packets, food growers will need to refer to the Seeds Gazette – an Excel workbook released monthly that is exceptionally difficult to navigate. How apparent the Precision Bred status of an organism will be in the Gazette is not yet clear; it may be necessary to cross reference varieties against other lists or registers.
Devolved nations and Europe
| The GenTech Act only applies to England. However, due to the Internal Markets Act, products placed on the market in England – including seeds – can also be sold into Wales and Scotland without being subject to the national GMO regulations that would otherwise apply. But new GMO seeds planted in Wales and Scotland will also have to be treated as GMOs and it will be the growers’ responsibility to ensure that they successfully identify precision bred varieties – something that could prove to be very difficult without adequate labelling. |
The status of new GMOs in Ireland is the same as in Europe – the Internal Markets Act does not apply and they are considered the same as old-style GMOs. This may change with forthcoming legal changes in Europe. In the meantime, however, growers in Northern Ireland may also face problems.
In the potential absence of adequate labelling, companies that wish to export conventional seeds to Europe or sell them in Northern Ireland may face additional costs due to having to prove that any seeds they sell are not new GMOs. This could affect sellers of all seeds for which there are new GMO varieties.
Organic and non-GMO sectors
The GenTech regulations currently passing through Parliament are already woefully inadequate with regard to measures that will allow the co-existence of organic and conventional food alongside the production, trade and sale of newer forms of GMOs. All of the costs and responsibility for ensuring that new GMOs are kept out of other supply chains will fall on operators within those supply chains.
The labelling of seeds is the final thing that tethers the co-existence of non-GMO sectors to any kind of realistic future. Without it, growers who wish to avoid new GMOs, and their distributors, customers and communities, will be entirely cut adrift.
Guidance on completing the consultation
- Here is a link to the pdf document for those who want to view all the questions in advance.
- Respond to the consultation here.
- We recommend opening two windows or tabs at once, one with the consultation and one with the guidance below, so that you can look at the guidance while you are filling in the consultation.
- Please feel free to get in touch with GM Freeze if you have any problems. Tel: 0845 217 8992.
Where questions ask about business impacts, and may not seem applicable to you, consider a response along the lines of:
- “I am in the business of growing food for my family and my community, this will impact us by…”
- “I am in the business of buying food from my local veg box supplier, this will impact us by…”
- “I want to be able to access organic and non-GM food, this question is my business because…”
- “I support organic businesses, and this question is my business because…”
The questions
1-8 – About the respondent
Although many of the questions relate to the commercial implications of proposals, it is a public consultation and individuals can respond to the questionnaire too.
9-14 – These all relate to the creation of a Precision Bred Plant Variety List. DEFRA have already told GM Freeze they are going to introduce this, and that the consultation in this respect is more of a questionnaire to assess business impacts. Nevertheless, it is worth making the case for the PB Variety list as DEFRA’s conduct in this area does not engender confidence. The relevant questions are as follows:
9a. Based on the explanation in the supporting information, do you understand the
proposed process and requirements for the Precision Bred Plant Variety List for
England for agricultural and vegetable plant varieties? (Please select one option
only) [Yes / No / Unsure]
- Yes
9b. Please explain your answer to the previous question [Free text]
- I have read the information provided.
10a. Do you think the proposed Precision Bred Plant Variety List for England for
agricultural and vegetable plant varieties will impact your business? (Please
select one option only) [Yes / No / Unsure]
- Unsure
10b. If you answered yes to the previous question, what changes do you anticipate
your business will have to make to adhere to the new legislation? (Please select
all that apply)
- [No need to answer this question]
10c. Please provide further details of any changes your business may have to make
to adhere to the new legislation. [Free text]
- [No need to answer this question]
11a. Do you think the proposed Precision Bred Plant Variety List for England for agricultural and vegetable plant varieties will benefit your business? [Yes / No / Unsure]
- Yes
11b. If you answered yes to the previous question, what benefit(s) do you think the Precision Bred Plant Variety List for England for agricultural and vegetable plant varieties may have on your business? [Free text]
- Issues you may want to raise include:
- It would aid freedom of choice over whether I plant new GMOs/PBOs.
- It would mean I do not have to spend time cross referencing other registers to find out if certain varieties are new GMOs/PBOs.
- For businesses:
- It will engender trust between DEFRA as an agency and my business and our customers.
- If there is no list it is unclear how I would maintain my organic or non-GMO status, and this may mean the end of my business.
- For non-commercial growers, consumers, and concerned citizens:
- I support organic and non-GM growers, and if there is no list it will threaten the status of their businesses.
- I want to be able to buy PBO-free varieties for myself and my family, if there is not list then these supplies will be threatened.
12a. Do you think the proposed Precision Bred Plant Variety List for England for
agricultural and vegetable plant varieties will have a negative impact on your
business? [Yes / No / Unsure]
- No
12b. If you answered yes to the previous question, what negative impact(s) do you
think the proposed Precision Bred Plant Variety List for England for agricultural
and vegetable plant varieties may have on your business? [Free text]
- [No need to answer this question]
The following questions are leading as there is no place to state the costs of not having a PBPV List, however, you might want to respond anyway.
13a. Do you think your business will incur extra costs because of the proposed Precision Bred Plant Variety List for England for agricultural and vegetable plant varieties? [Yes / No / Unsure]
- No
13b. If you answered yes to the previous question, what costs do you think your business will incur because of the proposed Precision Bred Plant Variety List for England for agricultural and vegetable plant varieties? [Free text]
- For businesses:
- I would incur costs if there is no list as it is unclear where the information on a varieties’ PBO status would be held and how accessible it would be. The costs would be up to the value of my business.
- For non-commercial growers, consumers, and concerned citizens:
- If there is no list this may cost myself and my family’s ability to access PBO-free varieties.
- We do not yet know the potential costs to human or environmental health as there will be no publicly-available, peer-reviewed risk assessments or safety assessments regarding the impacts of PBOs.
14a. Do you agree to the publishing of notifications of the Precision Bred Plant Variety List for England in the Plant Varieties and Seeds Gazette? [Yes / No / Unsure]
- Yes
14b. Please explain your answer to the previous question. [Free text]
- It is unclear where else in the public domain information about the PB status of an organism would be.
Questions 15-19 are the questions that relate to labelling. Note that where the consultation refers to options that “do not require legislative changes” it is because labelling would require a legislative change.
15a. What information, if any, on precision bred plant varieties is important to your business? [Free text]
- The unique reference number for the new GMO/PBO.
- The modifications introduced.
- The techniques used.
- Details about any environmental risk assessments that have been conducted.
- Details about any health and safety tests that have been conducted.
- Details about which products they appear in.
- Details about any patents that may be relevant to the product.
15b. In what format should this information be made available? (For example, an accessible list or register) [Free text]
- Some information, including PBO status, should be available on the label and all marketing material such as catalogues.
- All lists and registers that DEFRA and the FSA maintain in relation to the PBOs should contain the rest of the information.
- The company’s own published documentation should contain the rest of the information.
16a. Would the mandatory inclusion of precision bred status on labels for seed and other plant reproductive material to identify them as precision bred have a positive impact on your business? [Yes / No / Unsure]
- Yes
16b. If you answered yes to the previous question, what positive impact(s) do you think the mandatory inclusion of precision bred status on labels for precision bred seed and other plant reproductive material may have on your business? [Free text]
- For businesses:
- Increase the chances of keeping genetically engineered/PB materials out of my production processes, and therefore the continued viability of my business.
- Build confidence with customers.
- Would enable customers to label products they sell as PBO, or PBO-free, should they wish to.
- Europe is expected to require seed labelling of new GMOs – it may mean that I am able to trade with European companies and would not otherwise be able to.
- For non-commercial growers, consumers, and concerned citizens:
- This is a vital issue for me as it is likely to mean the difference between being able to select a PBO-free diet for myself and my family, or having no choice at all.
- We do not as yet know what the benefits will be as we do not as yet know what harms will arise from new GMOs.
- This is crucial for my suppliers of organic/non-GM fruit and vegetables and therefore a crucial issue for me.
17a. Would the mandatory inclusion of precision bred status on labels for seeds and other plant reproductive material to identify them as precision bred have a negative impact on your business? [Yes / No / Unsure]
- No
17b. If you answered yes to the previous question, what negative impact(s) do you
think the mandatory inclusion of precision bred status on labels for precision
bred seed and other plant reproductive material may have on your business?
[Free text]
- [No need to answer this question]
18a. Do you think your business will incur extra costs if the mandatory inclusion of precision bred status on labels for seed and other plant reproductive material identifying them as precision bred was introduced? [Yes / No / Unsure]
- No
18b. If you answered yes to the previous question, what costs do you think your
business will incur due to the mandatory inclusion of precision bred status on
labels for precision bred seed and other plant reproductive material? [Free text]
- [No need to answer this question]
19a. Do you think your business will incur extra costs if no mandatory requirement to include precision bred status on labels for seed and other plant reproductive material is introduced? [Yes / No / Unsure]
- Yes
19b. If you answered yes to the previous questions, what costs do you think your business will incur if no mandatory requirement to include precision bred status on labels for seed and other plant reproductive material is introduced? [Free text]
- For businesses:
- My business may not be able to continue to uphold key social and environmental commitments we have made, and this may damage the viability of our business and damage trust with our customers.
- It would be an administrative burden for us to cross reference all seed or other plant reproductive material that we buy against registers or variety lists. It is unclear how this would work – if indeed it were possible – and how much time and expense it would cost us.
- It may mean that we are unable to trade with customers in devolved nations and Europe.
- For non-commercial growers, consumers, and concerned citizens:
- We do not yet know the costs to our economy of failing to label GM PBO seeds. There is likely to be an economic impact as a result of damage to our trade with Europe and internationally.
- We do not yet know the costs to our health of failing to enable freedom of choice in relation to new GMOs.
- We do not yet know the costs to our environment of allowing people to unknowingly plant new GMOs.
- The UK organic sector is now worth £3.7billion. This market will be threatened by failure to label GM PBO seeds.
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[i] DEFRA email to GM Freeze, received 19th March 2025.
[ii] As pointed out by Dr Michael Edenborough QC, specialist in intellectual property law, during a parliamentary discussion on the Genetic Technology (Precision Breeding) Bill, in June 2022.
